Theodore F. Monroe
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February 17, 2017
Published by Theodore F. Monroe at February 17, 2017
Categories
Suspicious Activity Reporting (“SAR”) forms the cornerstone of the Bank Secrecy Act (“BSA”) reporting system. Broadly speaking, federal regulations require all banks and financial institutions to […]
February 16, 2017
Published by Theodore F. Monroe at February 16, 2017
Categories
This is the third of four articles that will use the case to examine card-not-present fraud from a legal perspective. Part 1 described the case and […]
February 15, 2017
Published by Theodore F. Monroe at February 15, 2017
Categories
Recently, the criminal case against online merchant Jeremy Johnson in Utah that started back in June 2011 finally came to a close. After more than four […]
February 14, 2017
Published by Theodore F. Monroe at February 14, 2017
Categories
Late last month, the criminal case against Jeremy Johnson that started back in June 2011 finally came to a close. After more than four years of […]
February 13, 2017
Published by Theodore F. Monroe at February 13, 2017
Categories
Payment companies get sued. It is a normal course of business. They plan for it and they are willing to pay for it. The truth is, […]
February 12, 2017
Published by Theodore F. Monroe at February 12, 2017
In November 2015, the Federal Trade Commission (“FTC”) reported its spearheading of a nationwide crackdown (known as Operation Collection Protection) along with more than 70 federal […]
February 10, 2017
Published by Theodore F. Monroe at February 10, 2017
Department of Justice introduced Operation Choke Point in early 2013 as an enforcement initiative to choke off swindlers’ access to the payments system by targeting the […]
February 9, 2017
Published by Theodore F. Monroe at February 9, 2017
Categories
Little more than a year ago, the United States Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued written guidance to banks for extending merchant services to […]
February 8, 2017
Published by Theodore F. Monroe at February 8, 2017
The day has finally arrived: The federal government has decided to make payment processors and ISOs completely (and ridiculously) responsible for the “sins” of their merchants. […]